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Archive for April, 2014

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ISOC-Bulgaria response to the ITU Council Working Group on International Internet-related Public Policy issues public consultation on the following question:

What actions are to be undertaken by governments in relations to each of the international Internet-related public policy issues?

In particular the following list of issues have been noted as areas of work that the CWG- International Internet-related public policy and have been contributing to the work of the ITU.
– Multilingualization of the Internet Including Internationalized (multilingual) Domain Names
– International Internet Connectivity
– International public policy issues pertaining to the Internet and the management of Internet resources, including domain names and addresses
– The security, safety, continuity, sustainability, and robustness of the Internet
– Combating Cybercrime
– Dealing effectively with spam
– Issues pertaining to the use and misuse of the Internet

Answer: The Bulgarian government has undertaken long time before anyone at the ITU would even think about these issues a policy, which resulted in unprecedented (and almost not followed in other countries) growth of Internet penetration, affordability, and quality of the service. Information document № 7, provided by the MTITC to the ITU Plenipotentiary meeting in Guadalajara, Mexico in 2010 speaks for itself.
Bulgaria has waived any licensing or registration regime for the Internet service providers since 1999. Under the Law for Electronic Services, the state does not control or deals with the Internet names and addresses (though, one must point out, it still deals with the Internet numbers – a service, which is largely known as ENUM, and which trial is still being managed by the ITU).
ISOC-Bulgaria, having been part of the last 14 years of negotiations, and sometimes legal arguments between all interested parties in the country, believes that such a policy has proven as a very successful one for the general development of the Internet sector in the country.
Concrete comments on some of the issues:

– Multilingualization of the Internet Including Internationalized (multilingual) Domain Names
The government has been part of the ICANN IDN Fast Track process; thanks partly to the unsuccessful bid to obtain Cyrillic IDN ccTLD for Bulgaria, the ICANN policy was changed, thus giving Bulgaria, Greece, and other interested countries, to appeal for review of the first objection. Furthermore, the ICANN IDN program has proven to be working both in the Fast Track, and in the new gTLD part. We see this as an example of successful cooperation and coordination between the private sector, civil society and government, which is the essence of the multistakeholder model that proved to be so successful in Bulgaria.

– International Internet Connectivity
Thanks to the lack of regulation or licensing, or even just a registration regime, Internet Service Providers were able to compete with each other, and reach levels of prices, which make the Internet in the country accessible and affordable for everyone. Bulgarian ISPs are building their own international connections, thus competing successfully with the incumbent – a prerequisite for successful, user-oriented international internet connectivity.

– International public policy issues pertaining to the Internet and the management of Internet resources, including domain names and addresses
As mentioned above, Bulgaria by law does not license, register, control, or interfere in anyway with the domain names and the Internet addresses, and that’s a decision that has been supported by governments and parliaments on a constant base since 1999. The Bulgarian example shows that with less regulation, there’s more competition, better choices for the users, and the access to the Internet is both affordable, and very fast. We would encourage other governments to study and use this example. It is true, however, that to reach such a decision, the whole society need to get together – government, citizens, private sector, even the incumbent telecom was supportive of this decision, taken back in 1999, when the Bulgarian Telecom was still state-owned. We understand that such a policy may not be yet acceptable in countries, which have not reached that level of cooperation, but we must also stress that the results of such a policy, are extremely beneficial for every and each of the stakeholders – users, ISPs, government. At the same time, the policies of the governments, which were welcome in the area of the management of the Internet resources, were not so well prepared in the area of privacy and data retention, perhaps also because they were drafted and accepted in the Parliament neither with the participation of the broader Internet society, nor that of ISOC-Bulgaria. As a result, when the European Court of Justice struck down the Data Retention Directive a few weeks ago, we immediately urged the government to take measures and edit the Law for Electronic Communications by taking down the text that allow metadata collection with no court control.

– The security, safety, continuity, sustainability, and robustness of the Internet
The security is usually part of the work responsibilities of the Internet service providers, the telecom operators, and the users. The state has ratified the Budapest Cybercrime convention, and it has also engaged with the International Cybercrime Academy, based in Sofia, and other entities, in order to secure the Internet to a maximum degree possible, with the limited resources available with the governmental budget. This task can only be successful, if it is built in the form of a public-private partnership.

– Combating Cybercrime
As mention, the Budapest convention is ratified, and the state works in close coordination and cooperation with law-enforcement agencies, ENISA, and other relevant bodies. A Bulgarian MEP, Ivailo Kalfin, was rapporteur to the European Parliament on Cybersecurity.

– Dealing effectively with spam
This is purely into the realm of the private business. The government deals with incoming spam, at the front routers / gateways, and makes sure that spam does not reach the mailbox of users of governmental email services. Historically, commercial operators have proven quite good in dealing effectively with spam.

– Issues pertaining to the use and misuse of the Internet
We don’t see such an engagement by the government – if the Internet is “misused”, whatever this term means, there are ways to deals with the perpetrators.
Internet Society – Bulgaria